Internal investigation on suspicion of failure to prevent bribery—checklist

Copyright © 2025 LexisNexis
Published by a LexisNexis Corporate Crime expert
Checklists

Internal investigation on suspicion of failure to prevent bribery—checklist

Copyright © 2025 LexisNexis

Published by a LexisNexis Corporate Crime expert

Checklists
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The following questions and issues should be at the forefront of a lawyer’s mind when advising in relation to an internal investigation on suspicion of failure to prevent bribery. This Checklist should be read in conjunction with Practice Notes: The Bribery Act 2010—an introductory guide, Failure to prevent bribery—the offence and Self-reporting corporate offences.

Initial Considerations

Oversight

The top-level management of an organisation should be committed to preventing associated persons from engaging in bribery. They should foster a culture within the organisation in which bribery is unacceptable. Consider:

  1. •

    Has the company appointed an officer of sufficient seniority responsible for anti-bribery?

  2. •

    Does the Board, or an appropriately constituted sub-committee of the Board, have oversight of the work of the anti-bribery officer and any investigation arising out of reports of suspected bribery?

Internal reporting/Whistleblowing

  1. •

    Does the company have a defined whistleblowing strategy?

  2. •

    Is it well-known and enforced throughout the company?

  3. •

    Has your company got clear reporting channels for reporting suspected bribery?

  4. •

    Does the company provide a confidential whistleblowing help line?

  5. •

    If

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